SMArtX Advisory Solutions (“SMArtX”) is an investment management firm (TAMP) established
in 2018 to provide investment management and investment advisory services through other
investment advisory or financial services firms (“Advisors”). As of February 15, 2024, SMArtX
has assets under management of $22.9 billion SMArtX Advisory Solutions LLC is a wholly
owned subsidiary of SMArtX Technology Solutions Inc.
SMArtX owns and operates the SMArtX Platform and the Smart Xchange Platform
(collectively, the “Platforms”) through which SMArtX offers its advisory services to Advisors.
Through the Platforms, an Advisor can establish and manage a unified managed account
(“UMA”). SMArtX provides access to investment strategies or models (each a “Model”) through
the Platforms. Each Model is provided by either SMArtX, a traditional asset manager, a hedge
fund or alternative investment manager, or an index provider (each a “Model Manager”).
Excluding index providers, are registered either with the SEC or one or more state securities
regulator or affiliated with same. A Model Manager provides SMArtX with securities and weights
and transactional history associated with the Model in order for SMArtX to create and maintain
the Model Portfolio. Each Model Manager provides additional content (“Model Manager Content”),
including but not limited to commentaries on the Model and the underlying investment strategy,
also including general commentaries on the markets and the economy, historical. performance,
biographical information on relevant members of the Model Manager’s team, and descriptions of
the investment strategy or strategies utilized in the Model. All Model Manager Content represents
the opinions of the Model Manager providing the content, and should not be construed as
personalized advice, and is subject to change without notice.
SMArtX provides access to Model Manager Content and historical performance with relevant
performance metrics for each Model available on the Platforms. An Advisor or Advisor’s
Clients, (each a “User”) can review the information available and direct SMArtX to implement
one or more Models in the UMA. When a User selects a Model for a UMA, the User will provide
SMArtX with the amount of funds, either in terms of dollars or as a percent of the account’s
value, in the UMA to be invested in the Model. When a User invests in a Model on SMArtX,
SMArtX will implement the positions and trading activity of the Model in proportion to the
amount of assets invested.
The SMArtX platform will rebalance positions inside the sleeves automatically based on the drift
parameters to bring the UMA in balance with the selected Model(s). SMArtX does not
automatically rebalance the sleeves. The User shall be responsible for determining whether any
Model or any combination of Models are appropriate and suitable for the UMA account holder.
Users should consider the financial situation, investment goals and objectives, time horizon,
liquidity, and risk tolerance (“Investment Considerations”) of the UMA account holder to
determine if the select Model(s) are appropriate. The User is responsible for reviewing any
changes to the Investment Considerations of the UMA account holder and making appropriate
changes to the selected Model(s).
Users may choose to direct SMArtX to buy or sell individual securities in the UMA directly rather
than through a Model. This functionality is called Advisor as a Portfolio Manager (“APM”) and
allows the User to direct a portion of the UMA’s assets rather than opening a separate account
with a custodian. Users may choose to buy or sell stocks, ETFs, or Mutual Funds.
Users may provide instructions to restrict the purchase or sale of certain securities from the
UMA. Additionally, Users can provide instructions to harvest taxable gains or losses in the UMA.
Users may add
or decrease leverage for any selected Model, provided that SMArtX will limit the
leverage utilized to the UMA’s specified account configuration. For example, if a UMA has
Regulation T margin, Users may choose to use leverage up to two times the account value.
Certain Models may inherently apply leverage. Finally, if a Model invests in a security or other
asset that does not fit with a UMA’s account configuration, SMArtX will exclude that investment
from the UMA. Any of these customizations that are specific to a UMA may cause material
performance differences between the selected Model(s) and the UMA.
SMArtX Advisory Solutions LLC has added an extension of its platform services referred to as
SMArtY, which is a manager-sponsored strategist platform that harnesses the power of
SMArtX’s technology whereby end clients pay a platform fee only without the individual model
fee charges. SMArtY is built on the same technology that is offered through the SMArtX
platform. Advisors have the same UMA access to leading asset managers participating on the
SMArtY portion of the overall platform,
Assets Under Advisement
Assets as of February 15, 2024
Regulatory Assets Under Management (RAUM)
Discretionary $22,914,329,456
Non-Discretionary $0
Total RAUM $22,914,329,456
Assets Under Advisement $12,085,670,544
Total Client Assets Under Advisement $35,000,000,000
Source: SMArtX, assets as of 02/15/2024
Sub-advisor Services
SMArtX acts as a sub-advisor to other investment advisors unaffiliated with SMArtX. These third-
party advisors outsource some of their portfolio management services which they offer to their
clients to SMArtX. These relationships are memorialized in each contract between SMArtX and
the third-party advisors.
SMArtX maintains a limited power of attorney to direct trading of each UMA (“Trading
Discretion”) to purchase and sell securities in the UMA’s selected custodian. Trading Discretion
is granted to SMArtX through a Sub-Advisory Agreement with an Advisor (“Advisor Sub-
Advisory Agreement”). Custodians may require an additional agreement from each Client to
grant Trading Discretion to SMArtX. A User may choose to terminate the relationship with
SMArtX and revoke Trading Discretion of SMArtX at any time.
SMArtX also provides services and solutions to registered broker-dealers, banks, trust
companies, and larger registered investment advisors (“Third-Party Sponsors”) that want to offer
their own third-party platforms (“Third-Party Platforms”) to Advisors and Clients. Third-Party
Sponsors are responsible for selecting Models and Model Managers to participate on Third-
Party Platforms. Third-Party Sponsors can charge different fee schedules than SMArtX to
Advisors. Third-Party Sponsors maintain their own custodial accounts and/or custodial
relationships and offer execution and clearing services. Third-Party Sponsors can offer
additional services and have different requirements and qualifications for participating. Advisors
should carefully review a Third-Party Sponsor’s Disclosure Brochure to understand the terms
and conditions of the Third-Party Platform.
SMArtX makes available OCIO consulting services to its professional advisors. An advisor on its
platform provides their specific instructions for a portfolio construction and our service will
provide them with selections of various asset classes for them to consider. A conflict of interest
exists with SMArtX, which does not generally recommend any strategy, where fees are
assessed separately by the individual portfolio manager and SMArtX can receive an overall
higher fee from a customized portfolio created under its OCIO service.
SMArtX does not currently offer a “wrap fee program” to Advisors.